Page 101 1 interested in what you learned from All right. 2 Did you learn from either any correspondence or a 3 telephone call with any third party that whether 4 again prior to the -- let me start again. Prior to the filing of the lawsuit 6 against Jane Doe 1 and Jane Doe 2 against the United 7 States Government, did you learn from any source, 8 maybe a document, maybe a telephone call or a 9 conversation that you had with a third party 10 separate from your client, that . was a victim or 11 was deemed to be a victim by the United States 12 Government or the United States Attorney's Office? 13 MR. SCAROLA: Same objection and 14 instruction. 15 BY MR. CRITTON: 16 Q. Same question with regard to III. Miller. MR. SCAROLA: Same objection and 18 instruction. 19 BY MR. CRITTON: 20 0. And same question with regard to Jane Doe. 21 MR. SCAROLA: Same objection and 22 instruction. 23 BY MR. CRITTON: 24 Q. Prior to your filing the lawsuit with 25 United States Government, did you ever any PROSE COURT REPORTING AGENCY, INC. EFTA00599762

Page 102 1 conversations with the United States Attorney's 2 Office -- 3 MR. SCAROLA: I assume -- 4 BY MR. CRITTON: 5 Q. -- regarding, regarding, regarding the 6 subject of the lawsuit or Jeffrey Epstein? 7 MR. SCAROLA: Same objection and 8 instruction. 9 MR. CRITTON: These are third parties; 0 where is the work product? 1 MR. SCAROLA: Work product has to do with I / anything that was done in connection with the I3 representation of these three clients. If he I4 had such conversations independent of his 15 representation of those clients, then he can 16 respond to the question. 17 BY MR. CRITTON: 18 Q. Well, let me ask you a broader question. 19 After you filed the lawsuit against the United 20 States of America, were you aware that Marie 21 Villafana or the United States Attorney's Office 22 represented the USA, correct? 23 A. Yes. 24 Q. All right. Did you ever speak with Marie 25 Villafana during, during the pendency of that PROSE COURT REPORTING AGENCY, INC. EFTA00599763

Pan c 103 litigation which is still pending today? 2 MR. SCAROLA: And I assume that question is qualified by inquiring as to whether such a 4 conversation occurred with regard to any of the 5 three individuals who he is representing claims 6 against Mr. Epstein or the U.S. Attorney's Office, correct? 8 MR. CRITTON: Say that again? 9 MR. SCAROLA: Yes, sir. Are you asking 10 whether such conversations occurred that were 11 relevant to his prosecution of the claims on 12 behalf of his three clients? 13 MR. CRITTON: Sure. 14 MR. SCAROLA: Then, then the instruction 15 remains the same. The objection remains the 16 same. 17 BY MR. SCAROLA: 18 Q. So, even if, do you even if you talked 19 about it with Mrs. Villafana, even if your client 20 Mr. Edwards spoke with Mrs. Villafana about a 21 scheduling issue, it's your position that that is 22 what, work-product? 23 MR. SCAROLA: That's correct. We are not 24 going to discuss anything that Mr. Edwards did 25 in the course of the prosecution of his claims PROSE COURT REPORTING AGENCY, INC. EFTA00599764

Paqc 104 1 2 3 4 on behalf of his clients. MR. CRITTON: So, any question that I ask you with regard to conversations that Mr. Edwards had with the U.S.A.O.'S office, whether it was Mrs. Villafana or anyone else 6 from the time, with regard to the Jane Doe 1 7 and Jane Doe 2 versus U.S.A. case, you would 8 instruct Mr. Edwards not to answer those 9 questions? 10 MR. SCAROLA: That is correct. MR. CRITTON: So if I '2 MR. SCAROLA: Obviously pending -- 13 MR. CRITTON: -- let me just finish. 14 MR. SCAROLA: Obviously pending, obviously 15 pending some instructions or guidance from the 16 court with regard to how the court will 17 interpret the work-product privilege in this 18 context. I might also add that it is our 19 position that any such inquiry exerts a 20 chilling effect upon the work that Mr. Edwards 21 continues to do on behalf of his three clients. 22 It is intended as a means to obtain 23 discovery that would not otherwise be 24 available in those pending claims. It is 25 intended to annoy, harass, and embarrass PROSE COURT REPORTING AGENCY, INC. EFTA00599765

Page 105 Mr. Epstein in a lawsuit that has absolutely no foundation whatsoever, and was filed for purposes other than a legitimate claim against Mr. Edwards based 5 upon any good faith belief that he engaged 6 in any form of improper or tortious 7 conduct and -- II CRITTON: Done? 9 MR. SCAROLA: -- those inquires are not 1O reasonably calculated to lead to the discovery 11 of admissible and relevant evidence. So, for 12 all of those reasons, we object. 13 MR. CRITTON: And let me just put on the 14 record very briefly so at least at this point 15 in time this is all information that clearly is 16 relevant to the complaint as it's alleged. 17 I have received a, my client and I 18 have both received a letter from you 19 asserting a motion for fees and costs and 20 certain sanctions under 57.105, by not 21 allowing us to ask what are clearly, I 22 believe, relevant material, basic 23 discoverable information are preventing 24 our ability to get all of the facts here 25 such that we can make a reasonable PROSE COURT REPORTING AGENCY, INC. EFTA00599766

Page 106 1 decision as to whether or not the 57.105 motion and letter which you sent to me was filed in good faith or has any basis in it. We're unable then to, we'll be in large part unable to evaluate our o position. MR. SCAROLA: And our position is that those are decisions that should well have been made, could have been made, and should have been made before you ever filed the claim. MR. CRITTON: All right. Are we done? MR. SCAROLA: Yes. MR. CRITTON: All right. 14 MR. SCAROLA: At least for now. it MR. CRITTON: I'm shocked. IG BY MR. CRITTON: 17 Q. With regard to, with regard to the claim 18 Jane Doe 1 and Jane Doe 2 that is currently 19 pending -- or let me strike that. Jane Doe 2 -- 20 Jane Doe 1 and Jane Doe 2 against the U.S.A. that 21 was filed in July of '08, that case is still 22 pending. 23 A. Okay. 24 Q. Is that correct? 25 A. That was a question, yes. 1.4:•••ams- , t,. PROSE COURT REPORTING AGENCY, INC. EFTA00599767

Page 107 Q. All right. And have any, have you had any 2 discussions -- well, let me strike that. What's the 3 status of that case? 4 A. It's still pending. Q. Other than still pending is a, is there, 6 are there any outstanding motions? 7 A. No. Q. I want to ask, to get back to one question 9 with regard to both the Qtask and with regard to the 0 Fortis system -- well, let me strike that. 1 With regard to the hard copies of the 12 files that you had that is any paper files that you 13 had associated with the Epstein files, where would 1.4 they have been kept at RRA? 15 A. In a filing cabinet. 16 Q. And were the filing cabinets in your office or were they out in the general hallways? 8 A. They were filing cabinets in my office and in 9 other locations in the office. )0 Q. Okay. With regard to the Epstein related matters, where did you keep those if they were -- 22 and by that that is the hard copies, did you keep 23 those solely in your office or would they have been 24 both in your office and in other places throughout 25 RRA? PROSE COURT REPORTING AGENCY, INC. EFTA00599768

Page 108 1 A. There were times when they were in my office 2 and there were times when they were kept in filing 3 cabinets elsewhere on one of the RRA floors. I believe 4 there were five or six floors of RRA Q. Okay. Was there a central storage, say if 6 there were a number of files in this instance 7 relating to Mr. Epstein, could you send those to 8 basically central storage and if you wanted someone 9 could go down and pick them up and bring them up to 10 you? 11 A. I don't know. 12 Q. Well, if you wanted to access something 13 that was in an Epstein file, and it wasn't in your 14 office, how did you access it; that is, a hard copy? 15 A. You're speaking specifically about 16 Mr. Epstein's cases or hypothetically with any cases? L/ Q. No, Mr. Epstein's cases? 18 A. As I sit here right now, I can't say with 19 absolute certainty that I ever had a piece of the hard 20 copy file requested for it to be brought to me. 21 Q. Well, with regard to Mr. Epstein's files, 22 though, if they were in a location, would it be a 23 correct statement that those were not, wasn't a 24 locked location or a secure location within the 25 contents of within the confines of the firm? PROSE COURT REPORTING AGENCY, INC. EFTA00599769

Page 109 1 A. I don't know that that's a correct statement. 2 Q. You don't know one way or the other? 3 A. The law firm was constantly expanding and 4 constantly under construction. For the most part in the 5 beginning the cases were kept in a, in a filing cabinet 6 in my office and later were kept in a filing cabinet, I 7 believe, in a locked storage location in another area of 8 the office. 9 Q. And did any attorney have access to that 10 storage area or do you know? 11 A. I believe any attorney could have had access. 12 Q. And if the attorney could have access, you 13 wouldn't necessarily know about it, true? A. Correct. !'5 Q. In the trustee's filing that they made in 16 response to my motion to preserve evidence, they 17 indicated that 13 boxes relating to Jeffrey Epstein 18 had been removed by the FBI or the government when 19 they came into the RRA offices. Do you remember 20 seeing that pleading? ml A. No. 22 Q. Okay. Are you, were there, in fact, 13 23 boxes of material or at least 13 banker's boxes of 24 material that related to matters directed to, 25 whether, whatever the content related to Mr. Epstein PROSE COURT REPORTING AGENCY, INC. EFTA00599770

Page 110 1 that you were aware of; that is, hard copies? 2 A. I don't know. 3 Q. Okay. Could have been more, could have 4 been less; you just don't know? 5 A. Correct. 6 Q. If I understood your testimony, 7 Mr. Rothstein, Mr. Rosenfeldt, any other attorney or 8 investigator could have accessed those files 9 depending or where they were within the firm, true? 10 A. I am not sure exactly who could have accessed 11 it. You asked me if the attorneys could and the 12 attorneys had swipe cards for various locked areas. 13 Each attorney I believe had access to any area where 14 those files were located. I believe so. 15 Q. Okay. Well, during the time you were 16 there did an individual by the name of Ken Jenne 17 work there? 18 A. Yes. 19 Q. Okay. Did an individual by the name of 20 Mike Fisten work for the firm -- 21 A. Yes. 22 Q. -- for RRA? Were they employees of the 23 firm or were they independent contractors? 24 A. I don't know. 25 Q. Okay. During the time they were there, PROSE COURT REPORTING AGENCY, INC. EFTA00599771

Page 111 1 did they also have swipe cards so that they could access different areas in the firm? A. I believe so. Q. With regard to when you joined RRA, did you ever have any further meetings with 6 Mr. Rothstein; that is, from the day you started at 7 RRA, did you ever meet Mr. Rothstein again? 8 A. By meet him again -- 9 Q. Did you ever have a meeting with him again 10 regarding your position in the firm? 11 A. No. 12 Q. Okay. Did you ever meet with him and a 13 number of other individuals with regards to firm 1 1 business? 15 A. No. I I Q. Firm cases? 1 , A. I don't believe so. 18 Q. Was Mr. Rothstein ever present in any 19 meeting where any of your cases were discussed? Let 20 me strike that. Was Mr. Rothstein ever present 21 wherein at any meeting where any of the cases 22 against Jeffrey Epstein were discussed? Don't tell 23 me content; just was he ever present. 24 A. How would I know that? I don't know. He 25 could, he could be in a meeting right now where the case PROSE COURT REPORTING AGENCY, INC. EFTA00599772

Page 112 1 could be discussed for all X know. 2 Q. I'm sorry. Obviously, where you, where 3 you were present. Where you ever present at a 4 meeting where Mr. Rothstein was also present where 5 the Epstein cases were discussed? 6 A. No. 7 Q. Did he ever call you to communicate with 8 you, call you either by phone, video conference, in 9 any fashion to discuss any act aspect of the cases 10 that you had against Jeffrey Epstein? 11 MR. SCAROLA: You can answer that. 12 THE WITNESS: He has communicated about 13 various, about legal issues related to the case 14 as well as commented about the case to me on 15 very few occasions but I would say less than 16 three times. 17 BY MR. CRITTON: 18 Q. During the time that you, from April of 19 '09 through late October of '09, correct? 20 A. In that time period, where, is that when 21 these -- 22 Q. Correct. 23 A. -- things happened? 24 Q. Well, that's the time you were there; 25 that's what I am asking. PROSE COURT REPORTING AGENCY, INC. EFTA00599773

Page 113 1 A. When I was there. 2 Q. And do you, can you remember the date, any 3 specific date that you spoke with him? A. No. Q. Do you remember any specific month that you would have had one of the -- well, what did you say something less than five conversations? I don't want to misquote you. A. I said less than three conversations. 10 Q. All right. So, something less then three 11 conversations you had with Mr. Rothstein regarding 12 Epstein cases, either legal issue or a comment, some 13 comment about the case to you, correct? 14 A. Yes. 15 Q. All right. The first time that he ever 16 spoke to you, did he call you or did you call him? 17 A. I, I never called Scott Rothstein about 18 anything. Oh, take that back. About anything related 19 to Jeffrey Epstein. 20 Q. The first conversation that you can recall 21 where either a legal issue or a comment was made 22 about Jeffrey Epstein by Mr. Rothstein to you, he 23 obviously initiated the call? 24 A. It wasn't a call. 25 Q. What was it? PROSE COURT REPORTING AGENCY, INC. EFTA00599774

Page 114 A. A comment in passing. And I believe I was sitting at a table in BOVA when he walked over to my 3 table and commented about Jeffrey Epstein. Q. Okay. Who were you there with at the 5 time? A. I don't remember. 7 Q. Were you with some friends? Were you with 8 other lawyers? 9 A. All right. I am jogging my memory. I, I have 10 no idea. 11 Q. What did he say? 12 MR. SCAROLA: To the extent that you can 13 answer that question without disclosing any 14 mental impressions with regard to the lawsuit 5 or any attorney-client privileged communications, you can answer. To the extent that it might invade either the work-product or attorney-client I , privilege, you should not respond. /0 THE WITNESS: Can I talk to you? MR. SCAROLA: Sure. 22 (A brief recess was held.) 23 MR. SCAROLA: Are we on? 24 THE VIDEOGRAPHER: Yeah. 25 MR. SCAROLA: The record should reflect PROSE COURT REPORTING AGENCY, INC. EFTA00599775

Page 115 that we have had an opportunity to consult and I have advised Mr. Edwards that there is no privilege protection for the particular communications involved. BY MR. CRITTON: Q. What did he say? 7 A. He commented to me, I want you to get that U pedophile. Q. And your response was what? LO A. I didn't respond. 11 Q. All right. Second conversation that you 12 can remember, where were you? 13 A. I had just come out of the conference room on 14 the main floor after taking a deposition in another 15 case. And he walked by and said, did you get that F'ing 16 pedophile yet. 17 Q. And your response? 18 A. Again. 19 Q. No response. 20 A. Didn't respond. 21 Q. On the first occasion when he came over 22 and if I understand correctly, all he said was the 23 comment that you referenced and then he left. You 24 didn't respond and then he just made the comment and 25 then left? PROSE COURT REPORTING AGENCY, INC. EFTA00599776

Page 116 1 A. Right. He was walking by in his normal, loud, ostentatious kind of way, greeting everybody in the restaurant. Came over to my table and he feels, at least my impression was obliged to say something to everyone. And that's the comment he said to me. 6 And if you've ever seen him, he is 7 basically always just skipping around and he hoped 8 on over somewhere else. So, yes, it was in, 9 literally in passing. 10 Q. Okay. How, how, how did he even know you 11 had cases involving Mr. Epstein? 12 A. I don't know. 13 Q. Because I think you testified earlier that 14 you had never discussed an Epstein case with 15 Mr. Rothstein one-on-one, correct? 16 A. Absolutely, true. 17 Q. You never discussed an Epstein case or 18 either of your three clients with Mr. Rothstein even 19 with a group of people around, correct? 20 A. Correct. 21 Q. All right. Do you remember a third 22 occasion that he spoke to you regarding Epstein 23 related occasion, cases? 24 A. Anything else that he ever spoke with me about 25 related to Epstein related issues is attorney-client and PROSE COURT REPORTING AGENCY, INC. EFTA00599777

Page 117 work-product privileged information that I am not going to divulge. 3 Q. Okay. I am not -- I need to still ask the 4 last question though. I thought you said earlier is 5 that you never had any substantive conversations, 6 maybe I misunderstood, with Mr. Rothstein about the 7 Epstein cases. Did I misunderstand you? 8 A. I don't believe that that was -- I had 9 conversations at a point about legal issues related to 10 Jeffrey Epstein and that's, that's it. 11 Q. Was that a one conversation? Was that a 12 number of conversations that you had where legal 13 issues were discussed as to, separate and apart from 14 the two comments he made about the case to you which 15 you were, you waived any privilege, work-product or 16 attorney-client privilege? A. I, I can't tell you. If you and I this 18 morning had a conversation and then we took a bathroom 19 break, and we had the same continuing conversation, I 20 don't know if that's one conversation or two. But I can 21 tell you the, the only time I remember Scott Rothstein 22 participating in any way, shape, or form in any 23 conversation related to anything substantive dealing )4 with, and not dealing with any specific client but a 25 legal issue, was on a particular one-day event, one-day PROSE COURT REPORTING AGENCY, INC. EFTA00599778

Page 118 1 conversation, if you want to call it. 2 Q. And that's at what time? At that time 3 legal issues were discussed? 4 MR. SCAROLA: Legal issue was the 5 testimony, a particular legal issue. 6 MR. CRITTON: Correct. A legal issue. 7 BY MR. CRITTON: II Q. When did that occur; that is, this one-day 9 discussion or a day discussion occur regarding a 10 specific legal issue? 11 A. I don't know. 12 Q. Was he present, he Mr. Rothstein and you 13 present at the same time? 14 A. Yes. 15 Q. Okay. Was anyone else there with you? 16 A. Yes. 17 Q. Who else was present? 18 A. Russ Adler, someone was on the telephone. I'm 19 not remembering who that was. I can't remember. I will 20 tell you if I do remember. 21 Q. Was Bill Berger there? 22 A. No. 23 Q. And, you don't. 24 let me strike that. Where did the conversation take 25 place? So, there was you. Well, PROSE COURT REPORTING AGENCY, INC. EFTA00599779

Page 1,9 J. A. Scott Rothstein's office. 2 Q. Had you been called up to meet with 3 Mr. Rothstein? A. Yes. Q. Okay. And who contacted you and told you 6 that Mr. Rothstein wanted to see you? 7 A. His, his secretary or paralegal or something. 8 Q. And did you get a call saying Mr. 9 Rothstein would like to see you right now, or was it 10 something that was scheduled? 11 A. It was not scheduled. 12 Q. So, you got a call and somebody told you, 13 come up, Scott, Scott wants to see you. 14 A. I don't remember exactly what was used, but it 15 was I believe, Russell is discussing a legal issue with Scott Rothstein; come to his office. 17 Q. Okay. Was the legal issue, did it involve 18 one of the Epstein cases or the Epstein cases? 19 A. It, it was a legal issue related to -- ys: . 20 Q. Okay. How long, how much time did you 21 spend -- well, let me strike that. So, when you 22 went up to Mr. Rothstein's office, it's -- I 23 understand you had to go through some security to 24 get in? 25 A. You've seen the video? PROSE COURT REPORTING AGENCY, INC. EFTA00599780

Page 120 1 Q. I actually haven't. A. Oh, really. Okay. Yeah, it's -- 3 Q. In order to get into Mr. Rothstein's 4 A. It's like a compound. Q. Kind of concern you that this guy running 6 the firm had a compound? 7 A. I -- at the time, no. In retrospect, okay, 8 now that we all know how this whole thing unfolded, but 9 at the time, no. 10 Q. Had you ever worked in an office? And you 11 had worked at some big offices. You worked at the 12 State Attorney's office in Broward County? '3 A. True. 14 Q. You worked for, I think for Kubicki 5 Draper? ;6 A. Correct. 17 Q. Did Mr. Kubicki, Gene Kubicki ever have a 8 compound around his office that you had to go 19 through any type of security either people and/or 20 locked doors or secured doors in order to access 21 him? 22 A. No. 23 Q. Had you ever worked other than the Broward 24 County Sheriff's, at the Broward County State 25 Attorney's Office with, and with Kubicki Draper, had PROSE COURT REPORTING AGENCY, INC. EFTA00599781

Page 121 1 you ever worked for a large firm? 2 A. No. You just named all the places I have 3 worked. 4 Q. All right. Is this the first time then 5 that you had been to Mr. Rothstein's office that he 6 called you up there? 7 A. No. 8 Q. You had been in his office before? 9 A. One time. 10 Q. And what was that occasion? 11 A. I was having back surgery, and I went there to 12 tell him I am having back surgery. As you know I had 13 back surgery, and I was telling him I don't know how 14 long I'm going to be off because, you know, the recovery 15 time is different for everybody. 16 Q. Is that the only thing you talked about, 17 the back surgery? 18 A. That's the only thing we talked about. 19 Q. Did the meeting you had with Scott, when 20 you went up, when you were called up to his office 21 that day, did that occur before your back surgery 22 episode or meeting or after? 23 A. After. 24 Q. So, you would, you had back surgery. 25 think you were out two or three weeks and then you twaSt.da•MCCI , PROSE COURT REPORTING AGENCY, INC. EFTA00599782

Page 122 1 returned to the office, and then that meeting would 2 have occurred? 3 A. Yeah, that's correct. 4 Q. When you, in order to get into the office 5 just as you have described it as a bunker, how many, 6 did you have to go through any security people to 7 get into -- 8 MR. SCAROLA: No, I think the description 9 was a compound. 10 MR. CRITTON: I will use compound. Are 11 you more comfortable with compound or a bunker? 12 I have seen it described both ways. I haven't 13 seen the video, but I have seen it described 14 both ways. 15 THE WITNESS: I will describe it for you. 16 Well, first I will answer your question. 17 Security people, I don't know if there was ever 18 a time where one would have to go through 19 security people to get to his office. But on 20 the day or two days that I have been in his 21 office, I did not encounter any security 22 personnel. 23 BY MR. CRITTON: 24 25 Q• A. Did you have to be buzzed into the It was more complicated than that. office? PROSE COURT REPORTING AGENCY, INC. EFTA00599783

Page 123 1 Q. How many security, different security 2 levels did you have to go through in order to get, 3 to go have your meeting with Mr. Rothstein and 4 Mr. Adler? 5 A. Two. 6 Q. And to your recollection you don't 7 remember ever seeing a security person? 8 A. Right. 9 Q. Okay. Who was in the office? 10 A. Well -- 11 Q. I'm sorry. 12 A. I do not remember seeing a security person 13 manning the door or granting access to his office. I saw security people every day in the office of RRA Q. All right. And when you got into the "6 office, Mr. Rothstein was there? 17 A. Yes. 18 Q. Mr. Adler? 19 A. Yes. 20 Q. There was someone on the telephone who you 21 don't recall? 22 A. Yes. 23 Q. Okay. Was there anyone else present? 24 A. Not that I remember. 25 Q. Okay. Was, were there any investigators, PROSE COURT REPORTING AGENCY, INC. EFTA00599784

Page 124 1 was Mr. Jenne or Mr. Fisten present? 2 A. No. 3 Q. So, it was, you, Rothstein, Adler, and 4 someone on the phone; that's it? 5 A. From what I remember. 6 Q. How long did the meeting last? 7 A. I don't know how long the meeting lasted. B Q. Five minutes or was it a substantially 9 long meeting? 10 A. Do you want how long I was in the meeting, 1 11 can give you an answer. How long the meeting lasted, I 12 have no idea. 13 Q. How long did the meeting last while you 14 were present? 15 A. Less than five minutes. 16 Q. Was the value of any of the three cases 1 / discussed at all? £1 A. No. 19 Q. Did Mr. Rothstein, did Mr. Rothstein 20 appear to be knowledgeable about your cases? 21 A. No. 22 Q. Mr. Adler, was Mr. Adler someone that you 23 had discussed the cases with on a somewhat regular 24 basis -- 25 MR. SCAROLA: Objection, compound. PROSE COURT REPORTING AGENCY, INC. EFTA00599785

Page 125 1 BY MR. CRITTON: 2 Q. -- not content. Was Mr. Adler someone 3 that you had discussed these Epstein cases with 4 prior to that meeting? 5 A. Yes. 6 Q. Was he familiar with the cases, generally? 7 A. He attended Jeffrey Epstein's deposition, so 8 he heard the questions asked and heard the Fifth 9 Amendment invocation and so the adverse inferences and 10 was therefore informed -- 11 MR. CRITTON: Move to strike as 12 nonresponsive. 13 BY MR. CRITTON: 14 Q. My question is was he familiar generally 15 with the subject matter of the litigation against 16 Mr. Epstein? 17 A. In that he read the newspaper articles about 18 molesting a bunch of children, yes, he was familiar with 19 the subject matter. 20 Q. And he read -- did you provide him with 21 copies of the pleadings in these cases when they 22 came to RRA? 23 A. No. 24 Q. What was the topic? What was the legal 25 issue that you discussed -- well, let me strike PROSE COURT REPORTING AGENCY, INC. EFTA00599786

Page 126 1 that. Who raised the legal issue, did 2 Mr. Adler raise it or did Mr. Rothstein? 3 A. I don't know. 4 Q. Okay. Well, how did the, who started the, if you were there I think you said five minutes, who 6 did the talking? 7 A. When I came in the, in the office, it was in the middle of a discussion. Q. Was a question posed to you? A. The question was on the table at least from my 1 perspective coming into the room and was then directed 12 at me, what's the answer to this particular legal issue. 13 Q. And what was the legal issue? 14 MR. SCAROLA: Let's talk for just a 15 second. 16 THE VIDEOGRAPHER: Are we going off the 17 record? MR. SCAROLA: Actually, we don't even have 19 to go off the record. Stay right here. 20 If this was an issue that was 21 identified during the course of the legal 22 proceedings to opposing counsel, then I am 23 going to allow you to you identify the issue without getting into any of the substance of the discussion regarding that PROSE COURT REPORTING AGENCY, INC. EFTA00599787

Page 127 issue. If it was not an issue that was identified in the course of the proceedings to opposing counsel, I am going to object and instruct you not to 6 answer on the basis of the work-product 7 privilege. 8 THE WITNESS: Work-product privilege. 9 BY MR. CRITTON: 10 Q. Do you know an individual by the name of 11 Fandry, F-a-n-d-r-y? 12 A. That name doesn't ring a bell right now. 13 Q. Do you know him to be -- does that name 11 mean anything with regard to, as an investigator, 1' Fandry? r, A. That's a male? ii Q. Pardon? 18 A. That's a first name or a last name? 19 Q. Last name, Richard Fandry. 20 A. I know an investigator named Rick that did 21 work, was contracted out by RRA to do investigative 22 work. I don't know his last name but -- 23 Q. Did, did Rick ever do any work on any of 24 the Epstein cases to your knowledge? 25 A. I believe so. PROSE COURT REPORTING AGENCY, INC. EFTA00599788

Page 12.8 1 Q. Do you know what the name of his business 2 was? 3 A. No. 4 Q. Is Rick still being employed at the 5 current time by your firm to do investigation? 6 A. No. 7 Q. Is Mr. -- I asked you earlier if you knew 8 Ken Jenne and Michael Fisten and you said yes and 9 you knew that they had an association with RRA; is 10 that correct? 11 A. Yeah, that's correct. 12 Q. And do you know whether they were 13 employees or whether they were independent 14 contractors? 15 A. You asked me that and I still have no idea. 16 Q. Did they have offices within RRA, 17 Mr. Jenne and Mr. Fisten? 18 A. They, Mr. Jenne definitely had an office 19 within RRA Mr. Fisten was normally in the field and I 20 assume he had a place to go in RRA I don't know if you 21 call it an office. 22 Q. Did you ever go 23 A. That's it. 24 Q. Did you ever go meet with him within RRA? 25 A. Yes. PROSE COURT REPORTING AGENCY, INC. EFTA00599789

Page 129 1 Q. Where did you go -- did you go to an 2 office to meet him? 3 A. Well, I went to a particular area, a locked area that I could get in with my swipe card and there 5 was a, a room like this. Is this an office? 6 Q. Sure. 7 A. Okay. Then yes. 8 Q. If you wanted to contact Mr. Fisten, did 9 you, did you have a number; that is, an inside 10 number? 11 A. I don't know. 12 Q. Did Mr. Fisten do work on the Epstein 13 related cases? 14 A. Yes. 15 Q. Okay. What kind of work did he do? 16 A. Investigator. 17 Q. Meaning what? 18 A. Meaning investigative work. 19 Q. Okay. Has Mr. Fisten continued to do -- 20 let me strike that. When RRA imploded in early or 21 in late '09, in October of '09, did Mr. Fisten come 22 to work for your firm? 23 A. Yes. 24 Q. Farmer, Jaffe. Is he an employee of your 25 firm? PROSE COURT REPORTING AGENCY, INC. EFTA00599790

Page 130 1 A. Correct. 2 Q. How about Mr. Jenne, is he currently 3 employed by your firm? 4 A. No. 5 Q. Do Mr. Jenne and Mr. Fisten, to your 6 knowledge, have any association at the current time? 7 A. No. 8 Q. Have, has Mr. Fisten continued to do work 9 on behalf of your firm; that is, investigative work 10 relating to Mr. Epstein? 11 A. What do you mean has he continued to? 12 Q. Has he continued, has Mr. Fisten done, 13 continued to do investigative work since he had been '1 with Farmer Jaffe relating to the Epstein cases? 15 A. On, on many cases and Jeffrey Epstein's case 16 being one of them, yes, he's done some work. 17 Q. Has he, has he as well -- well, let me 18 strike that. Has Ken Jenne done any work for any 19 outside agency, investigative agency or entity, done 20 investigation work relating to Jeffrey Epstein here 21 in the State of Florida? 22 A. I don't, I don't know. I don't talk to him. 23 Q. Have you had any contact -- well, let me 24 strike that. Did you ever have any contact with 25 Mr. Jenne during the time you were at RRA? PROSE COURT REPORTING AGENCY, INC. EFTA00599791

Page 131 1 A. Yes. Q. Did he ever do any work, or did you ever 3 direct him to do any work with regard to the Epstein 4 cases? 5 A. No. 6 Q. Did he know about the Epstein cases? 7 A. Yes. 8 Q. Okay. And how did he know? How did you 9 know he knew? Well, let me strike that. I think 10 you said you never directed him to do any work? 11 A. Right. 12 Q. Okay. And how do you know he was 13 knowledgeable about the Epstein cases? 14 A. I talked to him about it before. 15 Q. Did you discuss the facts and 16 circumstances of the cases with him? 17 A. Of .1 ., and Jane Doe's specific 18 circumstances, no. In fact, I would say, I would 19 highly, it's highly unlikely that he would even know 20 their names. 21 Q. But you have discussed the Epstein cases 22 with him generically? )3 A. Right. 24 Q. And did he approach you about discussing 25 the Epstein cases or did you approach him? PROSE COURT REPORTING AGENCY, INC. EFTA00599792

Page 132 1 A. He would have approached me. I didn't know 2 him. 3 Q. Do you recall why -- let me strike that. 4 Do you recall how long you were at the firm, RRA 5 before he approached you to talk about the Epstein 6 cases? 7 A. My recollection is several months. 8 Q. Okay. On how many occasions did he 9 approach you to talk about the Epstein cases? 10 A. I don't know. 11 Q. More than once? 12 A. Yes. 13 Q. More than twice? 14 A. Yes. 15 Q. More than five times? 16 A. Yes. Q. More than ten times? A. Possibly. Q. Okay. And with regard to Mr. Jenne did '0 you ever give him, was he ever an invite person on your Qtask? A. I do not believe so. Q. Did, did you ever ask Mr. Jenne why he was interested in your Epstein cases? A. No. C) PROSE COURT REPORTING AGENCY, INC. EFTA00599793

Page 133 Q. Okay. And on each occasion he approached 2 you about talking about the Epstein cases? A. On the first I occasion, definitely. I can't 4 say on every occasion that we had a conversation. Q. And if I understood you correctly, you 6 never assigned Mr. Jenne any tasks, any task; is 7 that correct? 8 A. That's correct. 9 Q. Did you find it odd or strange that he 10 would want to talk to you about your Epstein cases? 11 A. No. 12 Q. Did you, did you -- Mr. Jenne reported to L3 whom as you understood? 14 A. I didn't understand anything. Q. Do you know what his position with the 16 firm was? 17 A. No idea. 18 Q. Did he ever offer to help you with the 19 Epstein cases? 20 A. In some respect, I guess so. Generally, you 21 know, I, I can help. This is basically a criminal 22 matter; I can help. You know, that kind of thing. I am 23 not saying those are his exact words but paraphrasing 24 the gist of it, that's what I remember. 25 Q. Okay. Mr. Edwards, did you ever contact PROSE COURT REPORTING AGENCY, INC. EFTA00599794

Page 134 1 the media or the press when, that's located in New 2 York City, the State of New York, about any of the Epstein cases? A. I may have returned telephone calls that were initiated by press to me. Q. My, my question to you was, did you 7 initiate any telephone calls; that is, without returning a call to the, to any member of the media 9 or press in New York regarding the Epstein cases? 0 A. Meaning the first conversation Q. Right. 2 A. -- between -- yeah. No, I did not. 13 Q. Who contacted you from New York with 14 regard to any Epstein related matter? 15 A. The press. 16 Q. Who? 17 A. I don't remember anybody's name. 18 Q. Give me anybody's name that you can 19 recall. 20 A. George Rush. 21 Q. What media, what did you understand his 22 association? 23 A. I believe New York Daily News. 24 Q. Do you remember when Mr. Rush contacted 25 you? PROSE COURT REPORTING AGENCY, INC. EFTA00599795

Page 135 I. A. No. 2 Q. When Mr. Rush contacted you, do you know 3 why he contacted you; that is, what -- well, let me 4 strike that. When he contacted you, did you take 5 his call right away or was his a call that you had 6 to return? A. I don't remember. Q. Do you remember speaking with a person 9 named John Canally? 10 A. Yes. 11 Q. Okay. What was Mr. Canally's association? 12 A. I don't know. 13 Q. Do you know who he was with at the time? 14 A. No. 15 Q. What did your discussion with Mr. Canally; 16 that is, what was Mr. Canally interested in and what 1.1 did you tell him? 18 MR. SCAROLA: Objection, compound. 19 THE WITNESS: I, I listened to him more 20 than told him anything. 21. BY MR. CRITTON: 22 Q. Did you provide him any information? 23 A. In the back and forth of the conversation, I, 24 you know, maybe general information that one could read 25 from the newspapers I talked to him about. PROSE COURT REPORTING AGENCY, :INC. EFTA00599796

Page 136 1 Q. Did you speak with, other than -- on how 2 many occasions did you speak with Mr. Canally? 3 A. I don't know. 4 Q. On how many occasion's have spoken with 5 Mr. Rush? 6 A. I don't know. 7 Q. More than once with Mr. Rush? 8 A. I would say so, yes. 9 Q. More than five times with Mr. Rush? 10 A. That's approximate, that's approximately 11 correct. 12 Q. Okay. Mr. Canally, did you speak with him 13 on more than one occasion? 14 A. Yes. 15 Q. On how many occasion's have you spoken 16 with him? 17 A. I don't know. 18 Q. Five, two, three, your best estimate? 19 A. More than five. 20 Q. When was the last time you spoke with 21 Mr. Canally? 22 A. 2009. 23 Q. Have you had any contacts with the media 24 or the press during the year 2010, January, 25 February, March, and we're almost, well, we're PROSE COURT REPORTING AGENCY, INC. EFTA00599797

Page 137 1 almost at the end of March. In the last three 2 months, starting in January 1st of 2010, have you 3 had any contact with the press? 4 A. Not that I recall. 5 Q. Has the press contacted you, but you have 6 not returned their calls? 7 A. On hundreds and hundreds of occasions. 8 Q. Well, my question is since the beginning 9 of, since January 1st of 2010 has the press 0 attempted to contact you? 11 A. Yes. 12 Q. And if I understand your testimony, you 13 have not returned any of those calls? 14 A. To the best of my recollection I, I do not 15 remember speaking with anybody from the press during 16 this year, 2010. 1.7 Q. In 2010, do you have a recollection of 18 having spoken with people but saying you can't quote 19 me, i.e., I have no comment or I will tell you off 20 the record? 21 A. I don't even remember having those 22 conversations with anybody in 2010. If you know of 23 something and can refresh my recollection, I, you may be 24 able to remind me, but I don't think in 2010 I have had 25 any of those conversations. PROSE COURT REPORTING AGENCY, INC. EFTA00599798

Page 138 1. Q. The conversations you had with George 2 Rush, when you returned his call, what did Mr. Rush 3 ask you? What was he inquiring about? 4 A. My response to Jeffrey Epstein's comments. 5 Q. Which comments? 6 A. A telephone conversation initiated by Jeffrey 7 Epstein to George Rush related to the various cases and claims against Mr. Epstein. C) Q. Did Mr. Rush call you -- I'm sorry, I will improve it. If I understand correctly when Mr. Rush called you, that's the first time you knew who he was? A. I didn't know who he was before he called me, correct. Q. What did Mr. Rush tell you what Jeffrey Epstein had said to him? A. And I'm not sure that that was the first conversation I had with, with George Rush. Like I said in I think I've talked to him three or four, five times. 20 Q. Okay. Well, let me see if I can place, )1 can you give me a point in time when you first spoke 22 to Mr. Rush and when you last spoke with him the 23 approximately five times that you related? 24 A. Each of those times were in 2009 between, 25 earliest possible, June, I think, yeah, latest possible, PROSE COURT REPORTING AGENCY, INC. EFTA00599799

Page 139 1 I believe, November. 2 Q. And the first time that Mr. Rush called you, what was the subject? A. Jeffrey Epstein. Q. Okay. I assume you never talked with Mr. Rush about any topic other than Mr. Epstein, 7 correct? A. That's a safe assumption. 9 Q. When he first contacted you, can you 10 differentiate what he said on the first occasion 11 versus a later occasion? 12 A. I, I, no, in chronological order I can't right 13 now. I haven't gone back and thought about this like 14 this before. 15 Q. Did you ever correspond with Mr. Rush or 16 Mr. Canally by e-mail? 17 A. Mr. Rush, I believe that answer is no. With 18 Mr. Canally, yes. 19 Q. And so do you have copies of the e-mails 20 that you and Mr. Canally exchanged? 21 A. No. 22 Q. Okay. Would they have been while you were 23 at RRA, RRA? 24 A. Correct. 25 Q. With regard to Mr. Rush, if you did PROSE COURT REPORTING AGENCY, INC. EFTA00599800

Page 140 1 communicate with him by e-mail, would it be during 2 the time you were with RRA? 3 A. That's correct. 4 Q. Did you communicate with any other member 5 of the press during the time, we'll come back to 6 Mr. Epstein. During the time when you were at RRA, 7 did you communicate with anybody else by, by either, 8 first of all, by e-mail? 9 A. What is your question again? I'm sorry. 10 Q. Okay. Did you -- other than Mr. Rush who 11 you're not sure you communicated by e-mail, 12 Mr. Canally who you are sure you communicated by 13 e-mail during the time you were at RRA, was there 14 any member of the press, TV, written news media, 15 television that you communicated with -- 16 A. I'm sure. 17 Q. -- by e-mail? 18 A. I am sure there is. 19 Q. Okay. Do you remember any of their names 20 21 22 23 24 25 A. I don't know who that is. other than Mr. Rush and Mr. Canally as you sit here today? A. Not as I sit here today, I do not. Q. Did you ever communicate with Jose Lambiet? PROSE COURT REPORTING AGENCY, INC. EFTA00599801

Page 141 1 Q. He does a Page 2 or something with the, 2 Page 1, Page 2 of the Palm Beach Post? 3 A. No. I'm not, no. 4 Q. Okay. Have you ever spoken with Jane 5 Muskrat (phonetic)? 6 A. Again, I don't know who that is. 7 Q. Have you ever -- did you ever give or 8 allow one of your clients to give an interview to 9 one of the local TV stations? 10 MR. SCAROLA: Objection, compound. THE WITNESS: One of my clients gave an interview to one of the local television stations. 4 BY MR. CRITTON: Q. Which of your clients gave the interview? A. Jane Doe. Q. And did you organize that? 18 A. I assisted. 19 Q. Which, which TV station was it? 20 A. I don't remember. 21 Q. Do you remember who the person was from 22 the TV station that contacted you? Let me strike 23 that. How did it come about that Jane Doe gave an 24 interview to the TV station? 25 A. Various television stations have been PROSE COURT REPORTING AGENCY, INC. EFTA00599802

Page 142 interested over the course of these cases in having the 2 clients talk. I was adamant that that was not going to 3 happen and Jane Doe wanted that to happen. Q. How did Jane Doe even know that that 5 opportunity existed? If you didn't want it to 6 happen when the news, when the news people, when the 7 TV stations called you why didn't you just say my 8 clients are not available for interview? 9 A. What's your question? ,0 Q. The question is, is, with regard to the 11 T.V. station, you said multiple TV stations wanted 12 to do interviews with your clients. Did I 13 understand you correctly? A. You did. Q. And you said you didn't want any of your ICS clients to do interviews, correct? A. Right. Q. Okay. So, why didn't you just say, no, I am not making any of my clients available? lc MR. SCAROLA: I am going to object to the 21 extent that that calls for either mental 22 impressions or attorney-client privileged 23 24 25 communications and instruct you not to answer. THE WITNESS: I'm not going to answer based on the privilege. loaasasmausr.I. PROSE COURT REPORTING AGENCY, INC. EFTA00599803

Page 143 BY MR. CRITTON: Q. Jane Doe, though, did give an interview, 3 correct 1 A. That is correct. 5 Q. -- on TV and they blocked out her face? 6 A. That is correct. 7 Q. Were you there, were you present when she 8 gave the interview? 9 A. Yes. I0 Q. Okay. Did you see the interview on TV? ll A. No. 12 Q. Did they give you a copy of the tape of 13 the interview? 14 A. I believe a copy of the tape was sent to me. 15 Q. Okay. Do you still have that in your possession? A. No. i8 Q. Who has it? A. I believe it was destroyed. 20 Q. Who destroyed it? 21 A. Nobody destroyed it. 22 Q. Okay. You said, I think you said you 23 believe it's destroyed. How did it come to be 24 destroyed? 25 A. It was sent to me and it was kept in my house PROSE COURT REPORTING AGENCY, INC. EFTA00599804

Page 144 1 as I didn't believe it was any portion of the file and 2 my house flooded and the tape was destroyed. 3 Q. And did you try to play the tape? 4 A. I have never watched the tape. 5 Q. You still have it. You just think it's 6 destroyed? 7 A. No, I don't even have it. 8 Q. You threw it away? 9 A. It wasn't a matter of throwing anything away. 10 My entire house was full with water, every square inch 11 for 12 inches up the wall, and everything was just in 12 mud and got thrown in these huge bins and trashed so -- 13 Q. All right. Have you ever spoken with 14 Michelle Daryan? 15 A. Yes. 16 Q. On how many occasions have you spoken with 17 her? 18 A. Several. 19 Q. Have you e-mailed, exchanged e-mails with )0 her? - 1 A. Yes. 22 Q. During the time you, only during the time 23 you were with RRA? 24 A. I believe so. There, there could have been, 25 there could have been an e-mail. Oh I only think at RRA PROSE COURT REPORTING AGENCY, INC. EFTA00599805

Page 145 1 I believe that's right. 2 Q. As a result of Jane Doe speaking with the 3 press, did she receive any compensation? 4 A. No. 5 Q. Have any interviews been given separate 6 and apart from the TV interview that Jane Doe gave? 7 Did any of the other, did either of your other two 8 clients, . or III., ever give an interview to, 9 written to, to the written media, not TV? 10 A. No. 11 Q. With regard to, back to George Rush, you 12 said that Mr. Rush, Mr. Rush contacted you. You 13 recontacted him, correct? 14 A. That's correct. 15 Q. Okay. And what was the subject matter? 16 What was Mr. Rush interested in talking with you 17 about? 18 A. Jeffrey Epstein. 19 Q. Okay. And what, what specifically about 20 Mr. Epstein? How did he even know you existed, did 21 he say? 22 A. I don't know. Or, or if I knew, I don't 23 remember how he knew that. 24 Q. Okay. Did you, did you talk to him? 25 A. Yes, I did talk to him. PROSE COURT REPORTING AGENCY, INC. EFTA00599806

Page 146 1 Q. Approximately, how many, how long have 2 your conversations been? 3 A. Short. 4 Q. And with regard to George Rush, what, you 5 said he was interested in talking about Jeffrey 6 Epstein. What was he interested in? 7 A. I don't remember specifically the issue, but 8 it seemed to me that he came to me with an issue each 9 time, something related to the case. 10 Q. Okay. The case being Mr. Epstein's case 11 or your three cases? 12 A. I think that it was typically in general 1.3 related to the various criminal acts committed by 14 Jeffrey Epstein against the large number of girls in 1 1, each of the states that Jeffrey Epstein has lived in. I 16 think that was like the gist of his communication to me. I / Q. Well, did he? A. Or why he was interested. lq Q. Did he indicate to you that someone had )0 told him that, that certain acts had occurred in 21 other states or locations other than the State of 22 Florida? 23 A. I can't say with any degree of specificity 24 what was said, but that certainly is the impression that 25 I have right now thinking back. So, I believe that that PROSE COURT REPORTING AGENCY, INC. EFTA00599807

Page 147 was something he was conveying to me. 2 3 5 6 Q • Okay. Did he tell you that he had any information that Mr. Epstein had been involved with any other individuals in any other states, females? A. I don't remember. Q. Did you tell him or did you disclose to 7 him that you were aware of Mr. Epstein having been, 8 having assaulted underage females in other states? 9 A. I don't remember. 10 MR. CRITTON: Need to take -- why don't 11 we, why don't you change the tape now? 12 THE VIDEOGRAPHER: We're now off the video 13 record. It's 1:02 p.m. 14 (A luncheon recess was held.) 15 * * * * * 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. EFTA00599808